GlaxoSmithKline (GSK) announced this week that it will stop compensating health care professionals (HCPs) for speaking on the company’s behalf regarding its products and related disease areas to other HCPs and attendees who potentially could prescribe or influence the prescribing of the company’s products. GSK also announcenced its intent to educate HCPs by strengthening its own medical and scientific capabilities, improving the company’s multi-channel capability to provide appropriate and convenient product and disease state information to HCPs, and supporting fair, balanced and objective medical education to HCPs through independent educational grants. GSK stated that it intends to implement this new model by 2016. GSK will continue to pay appropriate fees for services provided by HCPs to GSK for clinical research, advisory activities and market research.
Additionally, GSK announced that it is expanding its “Patient First” program to all sales employees globally. The Patient First program was first implemented by GSK in the United States in 2011 in connection with its Corporate Integrity Agreement (CIA) with the Department of Health and Human Services Office of Inspector General (OIG). Under the terms of the CIA, GSK agreed that it will not provide incentive compensation or discipline to its sales representatives or their direct managers based on the volume of sales of GSK products within a given employee’s own territory or the manager’s district. The Patient First program provides for compensation based on evaluations of sales representatives’ business acumen, customer engagement, and scientific knowledge regarding GSK’s products.
Speaker programs have been a long-time area of focus for Government enforcers. Additionally, the OIG has demonstrated increased interest in the incentive compensation structure for sales employees. Earlier this year, Par Pharmaceuticals also entered into a CIA with the OIG that requires implementation of an incentive compensation structure for sales employees that does not take into account the volume of product sales within any given employee’s territory or the area of any given manager’s supervision. Are these developments emerging industry trends that we will see continue to develop in 2014?